Recommended Practices: Medical Re-certification

Overview

The medical re-certification process begins almost immediately following discharge
from treatment when the pilot normally meets with his/her IMS (Independent
Medical Sponsor). The IMS is the single most important individual involved in
medical re-certification. The IMS is the conduit for all information sent to FAA and
the person who sponsors the pilot for the SI (Special Issuance) medical. Selection of
the IMS is, therefore, a very important decision. In addition to examining factors
related to selecting the IMS we’ll also review several related topics. These topics are
the typical re-certification timeline, the P&P (Psychological and Psychiatric)
evaluation, other possible methods of regaining FAA medical certification for some
pilots, and coincident pilot licensing issues.

Selecting an IMS

The IMS (Independent Medical Sponsor) is an FAA AME (Aviation Medical
Examiner) who has undergone specific, specialized training. Some pilots in need of
an IMS may discover their regular AME is qualified as an IMS, but more likely
participation in the HIMS program will require a pilot to select a new medical
examiner. The decision of whom to select is a very important one. The IMS will be
the pilot’s representative to FAA regarding their medical qualifications, and once
selected, isn’t normally changed for the length of the pilot’s monitoring period. In
addition to conducting the necessary physical exams, the IMS will review and
compile all the records necessary for obtaining and maintaining a Special Issuance
medical certificate. In many cases, the IMS will also conduct sobriety testing. Since
the SI medical is only valid for 6 months, the pilot will also meet with the IMS
regularly. In many cases, the IMS will meet monthly with the pilot prior to re-
certification, quarterly through the first year, and semi-annually thereafter. Clearly
the selection of this physician, so central to the HIMS process, is highly
consequential to the pilot.

For many pilots the most important factors in selecting the IMS are location and
cost. Pilots prefer an IMS who is geographically close to more easily accomplish the
frequent required visits. Additionally, since sponsoring the pilot is such a time
intensive endeavor, many sponsors require a considerable up-front payment.
Sometimes this payment can result in a pilot feeling financially stressed, as many
pilots have just recently completed and paid for their residential treatment. While
location and cost are factors in making the selection of an IMS, they should not be
the only factors one considers.

Some IMS’ are highly experienced in sponsoring HIMS pilots. These physicians
typically have a good working relationship with other healthcare providers involved
with the pilot, and with FAA. Such relationships can aid a pilot in getting the
necessary testing and reports accomplished expeditiously and, therefore, the pilot
may return to flying more quickly. The speed of the pilot’s return should be driven
by clinical factors, of course, but administrative delays that aren’t clinically
necessary can dramatically increase the cost of medical re-certification for both the
pilot and the company. So, an efficient IMS with higher upfront costs may actually
be less expensive in the long run. These statements are not meant to imply that a
low or moderately experienced IMS cannot provide comparable service, but it is up
to the pilot to ensure the IMS they select places a priority on getting them medically
re-qualified.

It is also possible the pilot’s employer has previously vetted a number of IMS’ to
determine which meet the needs of oversight and timeliness identified by the
company. In these cases, the pilot may be required to select from a limited list of
sponsoring physicians to comply with company requirements. A pilot should
contact their company’s HIMS, Human Resources, or management representatives
as necessary to determine their available options.

Timeline

Many pilots are understandably concerned about how long it will take for them to
complete the medical re-certification process. For many, their benefits will be
limited and not flying means no regular paycheck. Many are also concerned about
successfully completing the medical re-certification process as they’ve never been
previously unqualified. And, of course, pilots are creatures of habit and routine and
going through the HIMS process is a clear break with a routine most found
comfortable and reassuring. So, “How long will this take?” is a common question for
pilots entering the HIMS program.

The answer, unfortunately, is not always clear or simple. At almost every point in
the HIMS process, a delay can be experienced either because it was determined to
be clinically necessary or because of administrative issues. In many cases, the pilot
causes the administrative delay, but other individuals can also create delays.
Examples of such delays are: a pilot selects an assessor who is unfamiliar with FAA
criteria resulting in an expired physical prior to receiving a diagnosis; a pilot fails to
schedule an appointment with their IMS until well after discharge from residential
treatment; psychiatric or psychological reports do not meet FAA standards;
required reports to the IMS are delayed or missing; the package sent to FAA is
delayed, incomplete, or disorganized; etc.

Given the complexity of the HIMS re-certification process, there are multiple
opportunities for delay. The best guard against such delays is a proactive pilot who
is active in, and monitors the progress of, their own case. In many cases, company
HIMS representatives or other HIMS pilots may be able to provide some advice or
assistance to a pilot seeking medical re-certification. But, ultimately, it is the
responsibility of every pilot to monitor his or her own re-certification. Some pilots
who have performed this function well have been re-certified in considerably less
than 6 months. For other pilots, medical re-certification has taken a significantly
longer time. From our experience, a proactive pilot will “typically” be re-certified in
approximately 6 months. This “typical” timeline is depicted below.

The P&P

The “P&P” (Psychological and Psychiatric) evaluation is an important aspect of the
medical certification process, and one that is often looked to with some trepidation
by pilots. The purpose of the evaluations is to establish the pilot is developing
healthy recovery oriented thinking patterns, that there is no underlying psychosis
or neurosis that was masked by excessive alcohol or drug use, and that there are no
lingering cognitive deficiencies that may have been related to the alcohol or drug
use. For most pilots whose drug of choice has been alcohol, and who have been
identified at a relatively early stage in the disease process, the probability of
cognitive damage is small. For others, who may be in the latter years of their flying
career after many decades of drinking, cognitive deficiencies may be present.
Fortunately, for many of these pilots, cognitive problems usually improve over time
of their own accord once the alcohol or drug use is terminated. In some cases,
cognitive rehabilitation exercises may also aid in improving test results.

FAA requires the P&P evaluations occur no sooner than 30 days following release
from residential treatment. This requirement ensures the pilot has at least 60 days
sober and the brain is no longer under direct influence of the alcohol or drugs. But,
in some cases, such as the “late” stage pilots described above, a longer period of
sobriety may prove beneficial before undertaking the examination. If the P&P does
not go well, it generally requires a 6 month wait before it can be re-accomplished.
So, the choice of when to have the P&P should be based on the clinical factors of the
case as well as the economic ones.

Non-HIMS Certification

Originally, the HIMS program was designed to be a resource for the re-certification
of professional pilots. At the time, the perceived need was greater for that group
since their livelihood was dependent upon flying, and it was considered essential to
have the support and oversight of peers and supervisors to allow for an expedited
return to the cockpit. Pilots who didn’t meet the criteria for inclusion in HIMS were
required to establish their medical qualification through other means. For pilots
with an abuse diagnosis, these means often included some form of treatment and a
minimum 2-year period of demonstrated sobriety. However, these pilot cases were
managed on an individual basis, so there was some variability in the requirements
that were imposed. In many cases, pilots in this group benefited from working with
HIMS qualified AME’s. After successful completion of this non-HIMS rehabilitation
program, the pilot would be granted a normal medical license. A future alcohol or
drug incident would then result in revocation of the medical and a need to re-certify
under the provisions of a Special Issuance.

The non-HIMS program described above is still in use today, but there have also
been other programs developed. Some pilots who have come to FAA’s attention for
alcohol misuse have been granted a medical, but have also been placed under
monitoring by an HIMS qualified AME. Some non-professional pilots have been
placed in programs that have some of the elements of a HIMS program, but lack
other elements. Due to the varying nature of these programs, these programs are
not considered to be part of HIMS. These programs are, however, opportunities for
medical re-certification for some pilots diagnosed with chemical dependency illness.

Licensing Issues

There are multiple branches within FAA, and under some circumstances pilots
undergoing medical re-certification are also subject to actions taken by non-medical
branches of FAA. Specifically, certain violations will result in either a suspension or
revocation of a pilot’s flight ratings licenses (including written test results; flight
hours accumulated are not affected). These violations include such things as a
failure to report a DUI, falsification of the medical application, or a positive DOT
drug or alcohol test. Whatever the circumstances, it is best to consider these
licensing actions and the medical re-certification process as separate entities.

It is possible to complete the medical re-certification process while still under a
suspension or revocation order of the flying licenses. Of course, without the
appropriate licenses, the pilot is still prohibited from operating a commercial
aircraft. So, it is important to remember the interrelationship of these documents
and to plan for it during medical re-certification. Since the written licensing
requirements may be accomplished some time in advance of the practical test, a
pilot who’s planned properly may be able to receive a medical re-certification and
take the practical flight tests in a matter of weeks. Poor planning in this regard can
result in an end to disability benefits since the pilot is medically re-certified, while
the pilot lacks the flying licenses to return to work.